Cal DTSC Answers FAQ About New Definitions in Haz Waste Regs

California DTSC recently released an FAQ to help hazardous waste generators comply with revised and re-organized regulations that took effect on July 1, 2024.

"FAQ" #2 on the California GIR page relates to the definitions that were added to the state's hazardous waste regulations (22 CCR) with the adoption of the GIR in California.

View the FAQ on DTSC's website.

1. What new definitions are there due to the adoption of GIR (Generator Improvements Rule) in California?

The new GIR definitions are:

• Very Small Quantity Generator (VSQG): DTSC adopted the federal term for Very Small Quantity Generator (VSQG), which was formally known as Conditionally Exempt Small Quantity Generator.

  California’s hazardous waste program does not include conditions for exemption for VSQGs that the federal program specifies. However, there are regulatory and statutory provisions in California that apply to generators who generate VSQG quantities of hazardous waste.

• Central Accumulation Area (CAA): This definition describes areas previously referred to as “90-day” or “180-day” waste accumulation areas depending on the generator category. These areas are now formally defined as CAAs, aligning with the federal terminology.

• Non-acute hazardous waste: This definition specifies that hazardous wastes that are not acute hazardous waste or extremely hazardous waste are non-acute hazardous waste. This was done to aid with determining generator status.

• Large quantity generator (LQG): This definition was previously commonly understood but is now defined in the state hazardous waste regulations. There are also new requirements for LQGs with the GIR implementation including new federal Identification number re-notification requirements, new labeling and marking requirements, new pre-transportation requirements, new closure requirements, and additional requirements for incompatible waste storage. These requirements are discussed in more detail below.

The definitions above were commonly and historically used when discussing existing regulations and standards. However, they were not previously defined in the state hazardous waste regulations.

2. Which existing definitions were modified in California’s hazardous waste regulations?

The following existing definitions were modified:

• Small Quantity Generator (SQG): This definition was amended to specify that a small quantity generator is a generator who generates less than 1,000 kg of non-acute hazardous waste, less than or equal to 1 kg of acute hazardous waste, and less than or equal to 1 kg of extremely hazardous waste (HW) in a calendar month. This new definition specifies the types of hazardous waste being counted (acute or non-acute) to help in determining applicable regulatory standards.

• Acutely hazardous waste or Acute hazardous waste: This definition was amended to specify that acutely hazardous waste or acute hazardous waste are hazardous wastes that meet the federal listing criteria and are either listed in 22 CCR 66261.31 with the assigned hazard code of (H) or in 22 CCR 66261.33(e).

3. What is a Central Accumulation Area?

A Central Accumulation Area is any on-site 90-day or 180-day hazardous waste accumulation area in which hazardous waste is stored in units subject to regulations for either SQGs under 22 CCR 66262.16 or LQGs under 66262.17.

Lion Members can see a more extensive breakdown of the changes that came with California's adoption of the GIR in the 4-page exhibit added to Lion.com/Members.

Expert-led Title 22/RCRA Refresher Training

With overhauled hazardous waste standards in effect as of July 1, 2024 update training for hazardous waste personnel is crucial for sites seeking to stay in compliance.

Training with Lion in 2024 gives you an extra advantage: Lion instructors are well-versed in the RCRA Generator Improvements and how they affect generators in California. Lion has been updating and refining our hazardous waste training programs to address the new requirements since US EPA enacted them nearly a decade ago.

Check the schedule of upcoming instructor-led training (workshops and live webinars) to get up to speed before the new, stronger standards take effect.